Blue Pathfinder (Red Snapper Learning Ltd.) - Public Data Privacy Notice
25 May 2018
What is personal data?
Personal data is information that can be used to identify an individual living person, either through use of a single or combination of data sets. You have the right of control over who uses your personal data, what it is used for, and what the legal basis for this processing is.
Who are we?
Red Snapper Learning provides training, qualifications and learning services to officers from agencies and organisations working in the areas of civil and criminal investigation, enforcement and offender management.
We are also a fully accredited BTEC Centre (Edexcel/Pearson Centre No 02298) where we deliver a national programme of BTEC qualifications which qualify learners through the process of case building, investigative practice, community safety and restorative justice.
How do we process your personal data?
As a training and education provider, Red Snapper Learning work with both trainers and learners. As such the data we process and how we process it are clearly defined in to two separate categories, and for the purposes of this notice shall be referred to as ‘For Learners’ and ‘For Trainers’.
Name: Of the individual making the order booking:
So that we can create a unique account for you and record courses attended and ordered, completion status for those attending the course, and any certifications gained.
Of the student:
Often the person booking training will not be the person attending it. We need to know who will be participating in our courses so that we can accredit them and log a record of their learning and certifications.
Address: If you attend a course with a physical accreditation, we would like to be able to post this and any other related course materials to you.
Contact details: Of the individual making the order and students:
We require an email address be provided as part of our registration process so as to create a unique record for you, confirm details of your course, send any digital materials to you, and to allow us to communicate with you about the logistics of your training course(s). We will also need to send you any digital certificates for your records to verify attendance and completion status.
You will receive only communications relevant to your course unless you have specifically opted-in to receive other communications.
Company name: If you are ordering training on behalf of your employer, we would like to know who you work for. This will allow us to tailor course materials to suit specific organisational requirements, and is necessary for invoicing and payments.
CV: In order to work with you and to provide your application for employment to employers (our clients), we require a CV document so that we can more fully understand your professional experience, qualifications, and areas of expertise. We regard the contents of your CV to constitute personal data and as such will not share it with third parties (our clients) without your express written consent on a per-application basis (we will send you a ‘Right to Represent’ request).
Pay rate and benefits: If you are working as a contractor through Red Snapper then it is highly likely that we will be making payments to either your limited company or directly to you as a PAYE contractor. Understandably we will need to know your per unit rate so that we can pay you the correct amount for your work.
Ethnic origin: We do not request or meaningful process this information, however individuals should be aware that this data is collected if included in the contents of the CV provided to us through registration.
Religion: We do not request or meaningful process this information, however individuals should be aware that this data is collected if included in the contents of the CV provided to us through registration.
Nationality: If we employ you as a trainer on a PAYE basis, we will ascertain with you whether you are an EU national or not and therefore whether you would require sponsorship to maintain your visa/work status in the UK.
Photographs: We do not request or meaningful process this information, however individuals should be aware that this data is collected if included in the contents of the CV provided to us.
Verification checks: If you accept an offer to undertake a training contract through Red Snapper, then depending on the basis by which you are paid (namely PAYE, umbrella company, limited company, sole trader) we will require some documentation from you to fulfil our legal obligations by verifying your right-to-work in the UK, identity, and address. Documents we will request from you for these purposes will be treated as personal data and can consist of a selection from the below within each category:
Eligibility to work - Passport; Visa; Birth certificate; National Insurance number
Proof of identity - Passport; EU identity card; Biometric residence permit; Driving licence
Proof of address - Utility bill; Student Loan statements; Credit card/bank statement or letter; Government or council document giving entitlement such as from DWP or HMRC; Printed P45 or P60; Mortgage statement; Financial statement; Council Tax statement.
Address: We require a mailing address so that we may send to you any documents which we are legally obliged to provide following your completion of employment.
Nationality: Should you receive an offer of employment from Red Snapper, we have a legal obligation to ensure you are entitled to work in the UK. To that effect we must prove the status under which you are working in the UK, and therefore are required to verify your passport or visa status.
Age: Should you receive an offer of employment with Red Snapper, we have a legal obligation to verify that you are of the minimum legal age to undertake full-time work.
Bank details: If you accept a trainer role with us, we will need your bank details so that we can pay you for the work you perform on our behalf.
Background checks: Depending on the environment that you will be working in, or the nature of our client’s business, you will be required to undergo a number of background checks prior to engaging contract employment through Red Snapper. These will vary per situation, we will seek your express consent for each, and these would typically include some of:
Vetting (e.g. DBS check); criminal declarations; qualification certificates; employment references; bankruptcy; security clearances
Disability: We do not request this information but expect that upon accepting an offer of employment you should notify us if appropriate, to ensure that working conditions are made suitable for you.
Medical/Sickness: If you are working as a trainer on behalf of Red Snapper and you are unable to attend work due to sickness, we need to know so that we can provide suitable cover or notify the students that the session will not be running at the scheduled time.
Partner information If you are contracted to Red Snapper and provide your partner’s details as your Next of Kin (NoK). We do not process these details other than to store them securely in the event of an incident that might require us to contact your designated NoK. We reasonably presume that you will have notified your NoK of your intention to designate them, and that we will utilise the legal basis of vital interest for storing their details and contacting them in an emergency.
What is the legal basis for processing your personal data?
Typically we operate on the legal basis of contractual necessity. The minimal data we process about you is specifically for the purpose of providing and verifying your training. We will have been instructed directly by you or on your behalf by your employer to provide you with training services. The information collected will purely be for the basis of providing you with information about your course(s), delivering the content of that course to you, and providing and supporting resources like textbooks or certifications.
If you are working with us as a trainer, then we require certain additional information around your eligibility to work in the UK (legal obligation) and for the purpose of paying you for the work you have completed on our behalf (contractual necessity). Should you work for us as a trainer on a PAYE basis, we will be required to retain your data for 7 years according to UK employment law. We will need to process your personal data to manage your hours of work, pay you, and keep in touch throughout your tenure.
We want allow you to exercise your individual rights as a data subject; should you wish us to remove your data or restrict processing then we will pseduonymise that data where possible and remove as much data as we can so as to respect your request and rights. We will retain only your name for our reference, and details of your pay rate and courses delivered.
Sharing your personal data?
Red Snapper believe that if you wanted a third party to process your data, you would provide it to them directly, therefore we share your personal data with carefully selected processors only to provide essential parts of our service. In all instances this is only applicable where you become Red Snapper Learning trainer. In such instances, processors who supply essential parts of our service, and whom we would intend to share your data are:
Location: New Zealand (transferred using the EU’s adequacy decision under GDPR which states no further safeguards are required)
Purpose: To provide secure digital services for the signing of contracts and compliance documentation.
Purpose 1: To provide a timesheet management system so that trainers may submit their completed working hours for review and payment.
Purpose 2: Should you wish to fulfil your contract on a PAYE basis, Eden is our preferred supplier for the provision of umbrella company services. You are free to select your own provider for this and notify us of their details, however please note that we will not transfer personal data outside of the EEA without an EU adequacy decision, a data-sharing framework such as EU-US Privacy Shield, or using standard data protection contractual clauses mirroring the requirements of GDPR.
How long do we keep your personal data for?
Once you have registered with us, we will automatically delete your data after an inactive period of 5 years from the point of data collection; inactivity being defined by never engaging with us to book or attend training. You are of course free to remove your details or restrict processing of your personal data at any time – please see the section below ‘How to access and control your personal data’. You will receive notification via email from us informing you that we have stopped processing of and removed your data for your own records.
Should you complete a training course through Red Snapper, we feel that we should be able to verify your training or accreditation to a third party if you require us to. For this reason we will retain your attendance and completion status until you tell us you no longer wish us to. Should you have attended training with us but wish for us to restrict processing of your data, we will make all efforts possible to remove your personal data from our records and retain only that data which we are required to verify your certification/participation; we will not conduct any further processing of your data and all records will pseudonymised or anonymised as far as possible.
How to access and control your personal data
Please visit https://www.redsnapperlearning.co.uk/rights to view and exercise your rights around your personal data; how you may submit a Subject Access Request to understand what data we hold on you and how we use it; or to lodge a complaint about our use of your data.
Please visit https://www.redsnapperlearning.co.uk/cookies to read about the cookies used on our website, their purpose, and how you may manage use of them across various browsers (including blocking them altogether).
Data Protection Officer
For any questions or complaints about the processing of your personal data by Red Snapper Training or to make a subject access request, please send details of your enquiry to our Data Protection Officer, Ryan Farmer at firstname.lastname@example.org.